Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (12) TMI 549 - AT - Income TaxTP Adjustment - MAM selection - brokerage service income - CUP v/s TNMM - rejection of transactional net margin method adopted by the assessee and adoption of cup method as the most appropriate method by the learned transfer-pricing officer - HELD THAT:- As relying on assessee own case [2020 (3) TMI 1133 - ITAT MUMBAI] no hesitation in holding that the transactional net margin method is the most appropriate method for determination of the arm’s-length price of the brokerage service income earned by the assessee. Accordingly the adjustment made by the learned transfer pricing officer and confirmed by the learned CIT – A is not sustainable. Hence deleted. - Decided in favour of assessee.
|